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User Guide to Thresholds and Classification - Environmental ...

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182<strong>User</strong> <strong>Guide</strong> for <strong>Thresholds</strong> <strong>and</strong> <strong>Classification</strong>sa. ≥ 1, but < 3, for corneal opacity, where the effects reverse within 21 days after exposure <strong>to</strong> thesubstance; orb. ≥ 1, but < 1.5, for iritis, where the effects reverse within 21 days after exposure <strong>to</strong> the substance; orc. ≥ 2, for conjunctival redness, where the effects reverse within 21 days after exposure <strong>to</strong> thesubstance; ord. ≥ 2, for conjunctival oedema (chemosis), where the effects reverse within 21 days after exposure <strong>to</strong>the substance.The classification criteria above are based on the Globally Harmonised System for <strong>Classification</strong> <strong>and</strong>Labelling of Chemicals (GHS) (United Nations, 2007). See Appendix 12C for a comparison of the HSNO Actcriteria with the GHS criteria <strong>and</strong> Appendix 12D for comparisons with the EU risk phrases of effects on eyes.See Table 12.6 in Appendix 12B for an example of calculating a mean Draize score from an acute eyeirritation study.Substances mildly irritating <strong>to</strong> the eyeThe Globally Harmonized System of <strong>Classification</strong> <strong>and</strong> Labelling of Chemicals (GHS) (United Nations, 2007)acknowledges that substances classified as irritating <strong>to</strong> the eye may be only mildly irritating when the effectis fully reversible within 7 days. The Hazardous Substances <strong>and</strong> New Organisms Act 1996 (HSNO Act)classification system does not specifically mention this. However, this is a lesser degree of hazard.Therefore, a substance whose irritating effect fully reverses within 7 days is classified as category 6.4A, butthe identification of this hazard may state ‗mildly irritating <strong>to</strong> the eye‘ as opposed <strong>to</strong> ‗irritating <strong>to</strong> the eye‘.12.3. <strong>Classification</strong> of mixtures12.3.1. <strong>Classification</strong> of mixtures when data are available for the complete mixtureThe mixture will be classified using the criteria in sections 12.2.1 <strong>and</strong> 12.2.2, <strong>and</strong> taking in<strong>to</strong> account thetesting <strong>and</strong> evaluation strategies used <strong>to</strong> develop data for these hazard classes.Unlike other hazard classes, alternative tests are available for skin corrosivity of certain types of chemicalsthat can give an accurate result for classification purposes, as well as being simple <strong>and</strong> relativelyinexpensive <strong>to</strong> perform. When considering testing the mixture manufacturers are encouraged <strong>to</strong> use a tieredweight-of-evidence strategy as included in the criteria for classification of substances for skin corrosion, eyecorrosion, <strong>and</strong> eye irritation <strong>to</strong> help ensure an accurate classification, as well as <strong>to</strong> avoid unnecessary animaltesting.A mixture is considered <strong>to</strong> cause eye corrosion (category 8.3A) if it has a pH of 2 or less or 11.5 or greater. Ifconsideration of the alkali/acid reserve suggests the substance or preparation may not have the potential <strong>to</strong>cause eye corrosion despite the low or high pH value, then further testing needs <strong>to</strong> be carried out <strong>to</strong> confirmthis, preferably by using an appropriate validated in vitro test.January 2012 EPA0109

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